On Point blog, page 5 of 5
§ 901.07, Completeness Doctrine — Oral Statements
State v. Juan Eugenio, 219 Wis.2d 391, 579 N.W.2d 642 (1998), affirming State v. Eugenio, 210 Wis. 2d 347, 565 N.W.2d 798 (Ct. App. 1997)
For Eugenio: Eduardo M. Borda
Issue: Whether the state was properly allowed to admit into evidence, under the rule of completeness, certain oral “challenged statements in their entirety, to show consistency on significant factual issues,”
§ 901.03, Objection/Offer of Proof — Format (Q & A Encouraged but not Required)
State v. Richard Dodson, 219 Wis.2d 65, 580 N.W.2d 181 (1998), unpublished decision below
For Dodson: Michael J. Backes
Issue: Whether an offer of proof must be in question-and-answer form.
Holding:
¶15 The court in Milenkovich did not say, and we do not say now, that every offer of proof should be accompanied by a question and answer format. There are cases in which the evidentiary problem posed is easily resolved by statements of counsel.